Polar Investment Counsel, Inc. (hereinafter
PICI) is a Minnesota based securities and commodities brokerage firm registered
with and regulated by the Financial Industry Regulatory
Authority (FINRA), the Securities and Exchange Commission (SEC),
the National Futures Association (NFA), the Commodities
Futures Trading Commission (CFTC), and the securities regulatory agencies
of the various states.
PICI is a non-clearing brokerage firm, which
clears all of its customers' securities transactions through Hilltop
Securities, Inc. (HTS) - a Dallas based New York Stock Exchange (NYSE) and
Financial Industry Regulatory Authority (FINRA) member firm. In layman's terms, this means that our
clearing firm (Hilltop Securities, Inc.) holds all of our customers'
monies and securities positions. Under no circumstances is a check
for the purchase of securities ever to be made payable to PICI or to one
of our financial professionals, but instead checks are made payable to Hilltop Securities, Inc. or to some other securities firm. Please visit their web site
PICI is a member of the
Securities Investors Protection Corporation (SIPC). To learn more about how SIPC protects
the public investor, please visit their web site at
In addition to SIPC coverage, Hilltop Securities, Inc. insures each customer
(as defined by SIPC). It should be
noted that this insurance coverage protects against failure of the firm etc.,
NOT against market loss.
PICI is operated as an independent firm
as opposed to a traditional firm or wire house. Our typical financial
is an individual who has worked for a large traditional firm at one time
or another in their past, but comes to us (or one of our growing number
of competitors) because of a desire to do one or more of the following:
their own business, paying only for the services required by
the type of business maintained
to offer investment product which may not have been available at a prior
to price their services to their clientele as they see fit (discounting
The ability to establish a
retirement program (qualified plan) more suited to the
needs of a particular individual financial professionals
Absence of "politics" usually associated with the larger more traditional
Actually, the list of reasons for someone
joining a firm like PICI is almost endless. Several years ago, joining a
firm like ours involved considerable hardship and much greater financial
outlay for the average financial professionals. But with today's technology
(which seems to be improving weekly), one of our financial
professionals is easily able to compete
with a financial professionals working for a large traditional firm.
As a member of FINRA, PICI is charged with and responsible for the
supervision of each and every one of its financial
professionals regardless of their location. To accomplish this, we have in
place operational compliance procedures like any other firm. Some
of these procedures and policies are more stringent than are enforced by
other firms. This is not done to hinder business, but rather to protect
you, the public consumer, our financial professionals, and the reputation of the firm.
In the event that you are unhappy with any of the firm's policies, or in
the performance of any individual associated with PICI, we would ask that
you call us or e-mail us so that we may discuss the matter and rectify
the situation. Our door is always open, so to speak.
As a regulated entity, charged with determining (among
other things) the suitability of recommendations made to our clientele,
compliance with numerous securities industry and Internal Revenue regulations,
the firm can and does collect "personal and sensitive information"
concerning our clientele and others with whom we do business.
The firm only shares this information with others
"who have a legitimate need to know" for a legitimate business
purpose. Generally, our business affiliates, regulatory authorities, and on
occasion our auditors, or by court order, or to a legitimate law enforcement
In other than unusual circumstances our sharing of your
personal or financial information is limited to:
Financial service institutions, such as mutual fund
companies, securities financial professionalss, banks or other financial institutions with
whom we have marketing agreements.
Companies under contract to perform services for our
firm, such as data processing.
Should you wish us to supply your personal or financial information
to any third party for any reason such as (but not limited to) tax preparation,
we shall require a proper written release concerning such a matter.
Secure E-Mail Communications
At this time, we do not offer secured e-mail and we
recommend that all e-mail, which you submit directly to the firm, or to one of
our representatives not contain any confidential or sensitive information. Your
submission of any e-mail to Polar Investment Counsel, Inc. or any of our
representatives represents your consent for two way communication via e-mail.
On October 26th of 2001, House Rule #3152 otherwise known
as the "Patriot Act", was signed into law.
Among other things, this legislation places on all
financial institutions the burden and responsibility of positively identifying
all of their customers, and the monitoring of certain types of
transactions. Consequently, new regulations became effective April 24th
2002, for most brokerage and other financial institutions which mandate certain
procedures. Therefore the firm now requires that each new account submit
an acceptable (and current) copy of a government issued photo identification
such as a drivers license or passport upon the opening of any new account or the
re-documentation of any existing account which does not already have
identification documentation on file. Additionally, our clientele should
be aware that in this post 9-11 environment and in accordance with the
provisions of this act, greater scrutiny may be given to money and security
transfers of all sorts.
Correcting or Updating Your Information
If you have concerns about the personal or financial
information maintained by Polar Investment Counsel, Inc. or if you wish to
update that information (perhaps because of a change in your circumstances)
please call your financial professional or Polar Investment Counsel, Inc. (218-681-7344).
Annual notification of this policy will be made via
statement that the policy is available via the internet or upon request,
in hard copy.
CONCERNING OUR POLICIES IS AVAILABLE UPON REQUEST
WIRE TRANSFER OF FUNDS AND CHECKING
The firm generally requires that all account
financial obligations be met by Federal funds wire transfer into your account.
Additionally, the firm suggests that customers who maintain excess funds in
accounts which they may wish to access request check account privileges, as
clearing firm checks issued and mailed may require up to 10 days for delivery.
ACH transfer is the most efficient and cost effective way to
transfer money from your brokerage account to your personal
account. Contact your financial professional for more
SUGGESTIONS OR COMPLAINTS
We are always interested in your
input or concerns. Should you have a suggestion, concern or complaint,
please call Mike Jordan at (218) 681-7344.
To ensure accuracy, Polar Investment Counsel,
Inc. may at any time record any conversation by electronic device or other
means without audible tone or other notification.